Letter 2277: Form 8300 appointment letter: a Bank Secrecy Act examination is opening

What Letter 2277 is

The initial contact for a Title 26 Form 8300 examination, which the manual requires to be made by mail, never by phone. It comes with a Form 4564 information document request, a blank Form 8300, Publication 1, Publication 1544 and Publication 5264 (the Form 8300 examination process). The examiner may not call until 14 calendar days after mailing, and then only between 8 a.m. and 6 p.m. in your time zone (IRM 4.26.11.9, 4.26.11.9.2, Aug. 4, 2021; 4.26.11.9.6, May 29, 2019). Dealers in precious metals get Letter 4479 and insurers Letter 4155 instead.

The deadline

Appointment date in the letter; a minimum of 10 business days to secure a representative (IRM 4.26.11.9.5).

What to do

Read the IDR: the examiner will reconcile your retained Forms 8300 to FinCEN's records, compare your bank's CTRs to your filings, and ask for deposit slips, cash receipts journals, customer statements and your written cash-handling policy (IRM 4.26.11.10.4(5)-(6), 4.26.11.10.5). If you find unfiled forms, the manual has the examiner secure delinquent returns at the exam and count each one for penalty purposes (IRM 4.26.11.10.8, 4.26.11.10.8.1). A Form 2848 must be a specific-use authorization "correctly prepared for a Form 8300 examination" (IRM 4.26.11.9.1).

What Form 8300 is and who gets examined

Any trade or business that receives more than $10,000 in cash in one transaction, or in two or more related transactions, must file Form 8300 with FinCEN within 15 days of the receipt and furnish a written statement to each person named on it by January 31 of the following year. Cash means currency and, in some cases, cashier's checks, money orders, bank drafts and traveler's checks of $10,000 or less received in a designated reporting transaction. The filing has been electronic for most businesses since 2024, through the BSA E-Filing System. Car dealers, boat and RV dealers, jewelers, art and antique dealers, auction houses, travel agencies, attorneys and anyone who sells high-value goods for cash are the businesses the IRS examines most, and the lead often comes from the other side of the transaction: the bank's currency transaction reports show cash deposits that the business's Forms 8300 do not account for.

Letter 2277 opens that examination. It must come by mail, and the examiner waits at least two weeks before calling, so the letter is the first contact, with an information document request, a blank Form 8300 and the publications that explain the rules and your rights attached.

Preparing for the appointment

The examiner's method is reconciliation. Your filed Forms 8300 are compared with FinCEN's copy, your bank's currency transaction reports are compared with your filings, and your cash receipts journal, deposit slips and customer files are tested for transactions over $10,000 that produced no form. The written cash-handling policy is requested because having one is evidence of reasonable cause and lacking one is evidence of the opposite. Use the days before the appointment to run the same reconciliation yourself. If you find transactions that should have been reported, the examiner will secure the delinquent forms at the exam and each one counts toward the penalty, but a business that identifies its own misses and has the forms ready is in a better position than one that waits to be found out, both on the count and on reasonable cause. A representative needs a Form 2848 prepared specifically for a Form 8300 examination; a general power of attorney for income tax is not accepted. The Form 8300 guide covers the filing rules and the customer statement, and the penalty calculator shows the exposure on each unfiled form so you know what is at stake before the examiner arrives.

Questions about Letter 2277

Have a different notice? The IRS notice decoder lists all 77 in the order they tend to arrive.